Proposed Draft Regulations Addressing Hydraulic Fracturing and Additional Clarifying Amendments

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Comment From: Dr Doorish

3/30/18 @ 7:30 AM

As a New Yorker and a member of Environmental Advocates of New York, I strongly urge the Delaware River Basin Commission to use their rulemaking process on Hydraulic Fracturing to ban fracking and all associated processes from taking place in the bas...↓

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Comment From: Dr Doorish

3/30/18 @ 7:29 AM

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Comment From: Renee Vogelsang

3/30/18 @ 7:28 AM

I am writing today to urge you to, Ban fracking in the Delaware River Basin. Ban fracking waste transport, treatment, and disposal in the Delaware River Basin and to not permit Delaware River Water to be used for fracking. Here is a l...↓

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Comment From: Damascus Citizens for Sustaina... (B. Arrindell)

3/30/18 @ 7:23 AM

I am asking the DRBC to note the material from DCS's September, 2013 presentation to the DRBC at this link: https://www.dropbox.com/sh/85sf163ufql57iy/AABklVH2yH3kVoHl9xDsBGdza?dl=0 It includes ten 5 minute statements and references to back up th...↓

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Comment From: Helga Spector

3/30/18 @ 7:20 AM

My family and I VIGOROUSLY oppose fracking in the Delaware Valley Basin as well as the fracking waste waters to be disposed of in the Delaware river.

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Comment From: Cati rotger

3/30/18 @ 7:17 AM

Fracking would be terrible for the area. it would destroy nature and the beautiful environment.

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Comment From: Joe Levine

3/30/18 @ 7:13 AM

January 11, 2012 To: DRBC Re: Draft Regulations on Fracking From: Joseph Levine NYH2O / DCS / Citizens For Water 561 Broadway, New York, NY 10012 212.219.1038 x1 [email protected] My comments focus on migration of flui...↓ds and gases through natural faults and fractures in the DRB geology that will be precipitated by high volume, slick-water hydraulic fracturing. This issue is of critical importance because it will have a profound detrimental and potentially catastrophic impact on ground and surface water. There is no way to control migration of fluids and gases caused by fracking. The most recent draft SGEIS however dismisses the fact that migration of fluids and resultant contamination is a probability, although there is overwhelming scientific evidence to the contrary. Attached is a selection of reports, studies and scientific papers documenting migration of fluids and gases through faults, fractures and fissures in the naturally fractured bedrock geology of New York State. In response to the draft regulations there was a significant body of reputable, scientific work submitted by geologists, hydro-geologists, petrochemical engineers, many environmental engineering firms and various governmental agencies that addressed the migration/contamination link. However there is no indication, based upon the attention given this subject in the draft SGEIS 2011, that this material was reviewed or considered. The following is the greater part of any reference in the draft SGEIS made on the migration issue. On page 11 of the Executive Summary, the following is stated; "Chapters 5 and 6 contain analysis that demonstrate that no significant adverse impact to water resources is likely to occur due to underground vertical migration of fracturing fluids through the shale formation. The developable shale formations are vertically separated from potential freshwater aquifers by at least 1000 feet of sandstone and shales of moderate to low permeability...That shales must be hydraulically fractured to produce fluids is evidence that these types of rock formations do not readily transmit fluids. The high salinity of native water in the Marcellus is evidence that fluid has been trapped in the pore spaces for hundreds of millions of years, implying that there is no mechanism for discharge of fluids to other formations. Hydraulic fracturing is engineered to target the prospective hydrocarbon-producing zone. The induced fractures create a pathway to the intended wellbore, but do not create a discharge mechanism or pathway beyond the fractured zone where none existed before. Accordingly, there is no likelihood of significant adverse impacts from migration of fracturing fluids." It is in response to the above statement that I submit the attached compilation of reports that contradict the above statement in its entirety. But in terms of "no likelihood...from migration of fracturing fluids" (stated above), I submit an excerpt from the following USGS paper; A Regional Perspective of the Devonian Shale and Ordovician Utica Shale Total Petroleum Systems of the Appalachian Basin (September 2011) Robert T. Ryder, et al. 1U.S. Geological Survey, Reston, VA 20192, [email protected] "....For example, oil and gas generated and expelled from the Marcellus Shale in N.Y., Ohio, Pa., and W.Va. probably migrated vertically through about 1,500 to 4,000 ft of overlying shale and siltstone into Upper Devonian and Mississippian sandstone. In addition, a short time after vertical migration, large volumes of Marcellus Shale gas (from cracked oil or kerogen conversion) were expelled a short distance into underlying Lower Devonian sandstone and migrated either into adjoining anticlines or updip as far as 50 miles. Furthermore, oil and gas generated and expelled from the Utica Shale in Ohio and Pa. suggest the following migration patterns: 1) westward acrossdip migration for 30 to 80 miles through about 1,000 ft of underlying Ordovician carbonate rocks before entrapment in Cambrian reservoirs, and 2) vertical migration through about 1,500 ft of overlying Ordovician shale followed by updip migration as far as 50 miles before entrapment in Lower Silurian sandstone." In addition, the NYCDEP commissioned Hazen and Sawyer Report documents migration of gases that were recorded during the construction of the NYC water tunnels up to 7 miles through natural faults. The EPA recently documented migration of fluids containing fracking chemicals in water wells and an aquifer in Pavillion, WY. The same problems were documented in Dimmock, PA. There are numerous detailed scientific studies on rock fracture mechanics, that prove that fluids and gases can and will predictably migrate via faults, joints and fissures, known as migration pathways in an unpredictable variety of ways, and can find their way to ground and surface fresh water resources including aquifers. The hydraulic fracturing process will (as it is designed to) stimulate movement and release of gases and fluids through existing and fracking induced pathways through the naturally fractured geology. These fluids and gases are toxic; both naturally occurring (heavy metals, deep-seated saline waters, radioactive materials and gases) and introduced toxic fracking fluids (aka slick-water). The draft SGEIS Executive Summary Statement (above) summarily dismisses the large body of accepted scientific work on this subject or has based its conclusions on some other scientific study(s) or body of knowledge. In either case it would be valuable to the public and the scientific community if the draft SGEIS provided information or evidence that specifies what scientific research their position is based upon. This issue is so evidently a singular crucial aspect of the ultimate safety of hydro-fracking technology that appears to be without remedy. It certainly deserves proper attention and analysis. Attached are reports from (including but not limited to) several experts and environmental engineering firms that substantiate this position. The group includes Robert D. Jacobi (whose work on mapping faults and fractures with the Geology Dept - Rock Fracture Group at The Univ of Buffalo is some of the most extensive on the subject); Hazen & Sawyer for NYCDEP, Arcadis US for the NY Watershed Inspector General, Paul Rubin, Geologist/Hydrogeologist - HydroQuest; Jeffrey Thyne, Geologist and author of the Garfield Co Hydrogeological Study; Marc Durand, geological engineering professor (Universit� du Qu�bec � Montr�al) whose specialty is rock mechanics and hydrogeology, among others. This compilation of reports confirms the extensive pattern of faults and fissures in NYS (Appalachian Basin). Yet the draft SGEIS fails to reference relatively well known fault and fracture information, including the existence of up to date mapping. The draft SGEIS includes an outdated map (figure A; pg 9) that shows only a small fraction of the known actual faults in NYS (compare with Jacobi's map; figure B; pg 9). This lack of relevant and accurate documentation is incomprehensible and worthy of invalidating the study. Some of the most extensive studies on mapping of faults and fissures in NYS have been done by Robert Jacobi. This work has been endorsed and widely accepted by the scientific community (including the Society of Petroleum Engineers SPE, NYSERTA, and the NYSDEC) and has not been challenged by any scientific organization, and is often referred to as the most extensive, documented mapping of NYS geology. It's unacceptable that the DEC is not better informed; there is too much at stake. The Jacobi report; Basement Faults and Seismicity in the Appalachian Basin of NYS; Jacobi 2009, states; "seismic activity is most active along the myriad pattern of faults in NYS, ...thus, it is not surprising that almost all of the seismic events in the Appalachian Basin portion of NYS can be correlated with the known and suspected faults. It appears that more faults are seismically active in NYS than previously supposed. It may be that most of the basement faults that extend to the surface rocks are seismically capable, even those that do not have historical seismicity ascribed to them. Further work will undoubtedly modify the specific locations of fault traces and their seismic capability. However, the conclusion is inescapable that a large number of faults do exist in NYS, and that several of them have been seismically active." Gas shales are often the origin of hydrocarbon stored in conventional reservoirs. These hydrocarbons have been expelled, migrating upward into a trap of reservoir quality rock below a sealing unit (often shale). In gas shale systems, the shale is all three: hydrocarbons are generated, stored and held in place. The preserved organic matter is "consumed" through biogenic or thermogenic processes to generate smaller chain hydrocarbons (gas or liquid). The remaining carbon that cannot be converted (dead carbon) and clay minerals form a storage mechanism through adsorption, which increases tremendously the potential storage volume. The relationship between temperature, pressure, available volume and the general attractiveness of methane (partial pressure) will define ultimate adsorbed storage capacity. Even after a great amount of generated gas is expelled out of the shale (as source rock), there can remain an enormous quantity as adsorbed gas. Gas will also reside in rock matrix pore space and fractures if there is a "seal" to keep the gas in these spaces. I will not elaborate on seismic activity in this comment but do so for two reasons. One is that the Jacobi studies have so much to do with seismic activity, and second because of the recent reporting of earthquakes/seismic activity related to fracking (and/or injection wells) in Ohio and before that in Arkansas, Texas, England and elsewhere. The Ohio State geologist investigating the recent earthquake said that, "this could be avoided if more analysis (although costly) was performed so that wells intersecting with faults could be avoided" (Scientific American; Jan 3, 2012). This of course is likely impossible in NYS and PA areas of the basin where the faults are so densely populated with literally a matrix of criss-crossing fractures (as described by Jacobi) that it would be quite difficult if not impossible to avoid. Also taken from Jacobi's report: ...Part of the multidisciplinary approach developed (by Jacobi and Fountain 1996) was the identification of fracture intensification domains (FIDs; e.g., Jacobi and Xu, 1998; Jacobi and Fountain, 2001, 2002). The FIDs are characterized by closely spaced fractures, the strike of which defines the trend of the FID. The closely spaced fractures are also commonly the master fractures, even though they may characteristically abut other fracture sets in regions outside the FID. In interbedded shales and thin sandstones in NYS, fractures within the FID that parallel the FID characteristically have a fracture frequency greater than 2/m, and commonly the frequency is an order of magnitude greater than in the region surrounding the FID. Jacobi goes on to say; An important observation is that these seismically active faults crisscross a large portion of NYS. The high number of faults means that most cultural facilities (e.g., waste disposal sites, bridges, pipelines) are not far from a potentially seismically active fault. For example, the West Valley faults extend south to the West Valley Demonstration Project, a high- and low- level radioactive waste storage site. Similarly, the Attica Lockport Fault passes fairly close to the Darien Lakes theme park, where some of the highest amusement rides in the Northeast are located. And one final example: in the Mohawk Valley region, the south end of the Hinckley Reservoir dam is adjacent to the Prospect Fault. Thus, it is vitally important to assess the maximum credible seismic event that can be expected along these faults. The maximum credible seismic event is extremely difficult to determine, partly because the historical recurrence rates of all earthquake magnitudes are relatively low in NYS (especially the moderate magnitude events) and because there may be a disconnect on Gutenberg Richter curves between small events and maximum credible seismic events. And most relevant with respect to migration from Jacobi; Certain sets of fracture intensification domains are marked by soil gas anomalies commonly less than 50m wide (Jacobi and Fountain, 1993, 1996; Fountain and Jacobi, 2000). In NYS, the background methane gas content in soil is on the order of 4 ppm, but over open fractures in NYS, the soil gas content increases to 401000 ppm. (R.D. Jacobi / Tectonophysics 353 (2002) 75113 p79). "The high concentration of gas in the faults is consistent with why drillers seek out the faults, because this is where hydrocarbons exist in greatest concentrations because the faults provide both a pathway and collection zone." (Marc Durand) The Executive Summary also states "Hydraulic fracturing is engineered to target the prospective hydrocarbon-producing zone. The induced fractures create a pathway to the intended wellbore, but do not create a discharge mechanism or pathway beyond the fractured zone where none existed before. Accordingly, there is no likelihood of significant adverse impacts from migration of fracturing fluids." This statement is not accurate and cannot be scientifically supported. Some of the released gas (with luck possibly most) will migrate up the wellbore as desired. But there is no doubt that some (also possibly most if not lucky) will find other pathways. As per Marc Durand (below), fracking recovers only 20% of the gas in a reservoir until the well is capped due to productivity decline. The rest of the gas will migrate naturally - through the network of natural faults and fissues, including additional pathways opened up by fracking that were previously naturally sealed. Marc Durand, geological engineering professor (Universit� du Qu�bec � Montr�al) whose discipline is rock mechanics and hydrogeology states (Shale Gas Info March 12, 2011); "Hydraulic fracturing artificially creates a network of interconnected fractures towards which the gas begins to migrate. The technique initiates the flow of gas in the deposit as happened in the classic natural gas deposits over hundreds of thousands of years, but the (fracking) technique cannot speed up the geologic process. The construction of a well and it's fracturing are completed in a few weeks; the flow begins and continues on a geologic time scale. The amount of time before the well is closed (once the rate is no longer commercially viable) represents no more than an infinitesimal portion of the geologic time. Fracking gets out only 20 per cent of the gas (in a reservoir), a figure confirmed by Canada's National Energy Board. "After maybe eight years of production, the gas companies will seal and forget the wells, Durand said. That means that the remaining gas (80%), will continue to release itself from the shale (post fracking). The rock formations shattered by fracking will be thousands of times more permeable, allowing the remaining 80 per cent of shale gas and underground toxic water, 10 times more salty than sea water, to continue circulating, bubbling to the surface through disused (abandoned) gas wells. Over time, methane could leak into the groundwater and gas leaks could gush, uncontrolled, into the air. Because this happens deep below, it is not visible on the surface," Durand wrote in a paper raising questions about shale gas. Paul Rubin of Hydro-Quest makes the same case in this report (Scope of EPA Study on Hydraulic Fracturing, August 10, 2010). "Jacobi and Smith (2002) document the epicenters of three seismic events in Eastern Otsego County. These seismic events indicate that earth movement occurs from great depths along faults upwards to aquifers and potentially to exposure at the ground surface. The great lateral extent of these faults, and their visually observable connectivity with other faults, confirms that the process of hydraulic fracturing, which may interconnect naturally occurring faults and fractures, has a great a very real potential of causing contaminants to migrate to aquifers and surface water from localized zones across and beyond county and watershed boundaries. Fracking contaminants, once mobilized vertically along fault planes and fractures, especially under pressurized conditions, can reach freshwater aquifers. Even if all fracking fluids were comprised of non-toxic chemicals, the risk of interconnecting deep saline bearing formations and/or radioactive fluids is not warranted. Any commingling of deep-seated waters, with or without hazardous fracking fluids is unacceptable. Documented gas excursions near existing gas fields demonstrate that vertical pathways are open. If gas can migrate to the surface it is highly likely that hydrocarbon and contaminant rich Light Non-Aqueous Phase Liquids (LNAPL's) will also reach aquifers and surface water resources. These contaminants may then also migrate to down gradient wells, principal aquifers and waterways." So, what will be the legacy of shale gas hydraulic fracturing for NYS? Concerns regarding the aftermath are not addressed in the draft SGEIS except an oblivious assumption that the "sites" will be restored and look nice and grassy. That is the image that industry provides. Marc Durand provides the following analysis; Marc Durand, from Shale Gas A Business Plan Very Much in the Red: In 20 or 30 years how much will 20,000 depleted wells, which will simply have been concealed before being bequeathed to the geographic locale, cost us per year? There is total silence on this question, because the mining and oil sector has never been concerned for what happens to the drill holes afterwards. The industry has never allocated funds for that. The newest legislation requires only the rehabilitation of the site at the end of its exploitation. Companies must restore the surface of the site but there is almost nothing for what is underneath. There are thousands of well sites at the end of their life span, hidden in the surface vegetation which have become all the more dangerous because their location has been forgotten. In the United States, there are more and more reports of victims of explosions from gas which resurfaces from old wells. In the majority of cases, it is old exploration wells dating from the beginning of the last century (Appalachia, Colorado). The problem will take on a whole new dimension shortly with the end of life of the gas wells situated in layers, which have undergone intense modification by hydraulic fracturing. The technique, newly applied on a large scale, will leave thousands of abandoned wells under inhabited zones, without anything being known of the impacts which will arise at the end of the work. Lets be clear about what we understand by the end of the life-span of a shale gas well. A working well has a life of 3-5 years. It is an optimal plan for extracting the gas as quickly as possible at the lowest cost. The output the fractured shale delivers is very high at first, then it diminishes logarithmically or exponentially. The wells are abandoned when the rate of gas is deemed unprofitable; at which point about 20% of the gas in place has been captured. In classic gas reservoirs, up to 95% of the natural gas can be captured. For shales, recoveries are expected to be around 20% because of low permeabilities, despite high- density horizontal drilling and extensive hydraulic fracturing . (National Energy Board, A Primer for Understanding Canadian Shale Gas). At the end of this period the extraction well is summarily transformed for another job or task whose sole purpose is to stop the flow of gas in the well. By means of blocking down hole plugs, cement plugs in the tubing, etc., the temporary extraction site must be turned into something permanent, the function of which is very different. In reality, practically nothing changes in the structure and composition of the well but the addition of a permanent plug. Whatever the design of the plug, the new work cannot have a drastically modified life-span. Nevertheless, these plugged wells must resist in perpetuity the pressure of the methane, which will continue to seep from the fractured shale. And let's not forget that 80% of the gas remains in the shale at the end of extraction. Underneath the inhabited plain, the Utica will have become an extremely permeable reservoir, still containing the left over methane after the skimming of the 20%. This enormous volume, 100 metres thick times 10,000 Km squared will be directly connected to the surface by 20,000 slowly corroding wells .The steel pipes and the sealing grout in an extremely saline environment will erode. This will possibly vary in speed from one well to another according to the quality of the sealing work done. The life duration of each of these wells, is the time before the deterioration is so advanced that major leaks force the authorities to intervene. From then on there will necessarily be a cost . This cost may appear very early in the process for certain wells, as has happened in Qu�bec with some wells whose exploitation phase hasn't even begun; but for now, the industry is still the owner of the wells and so pays the cost. This demonstrates though, that leaks occur even with brand new wells. Figure 1 shows various routes the gas can take to reach the surface and drinking water wells. (P) The light blue letters (A,B,C) show the gas flow in the case where the drilling intersects a flaw or a long fracture. It is difficult to estimate in what proportion of wells this could occur because a detailed geological map is not readily available for the rock under the soft deposits of the St. Lawrence Valley. Figure 1 : possible leaks for an extraction well capped well. Where there is the presence of such a fracture, the injected liquid opens this route and pushes very far (A) into the Lorraine strata. The flow path is opened permanently to continue into the sandstone and other more permeable layers. Gas leaks show up in the artesian wells and the dwellings in proximity to the fault. Note that the fracturing fluid also penetrates a great deal further than the fault in the limestone (A) The Trenton is more permeable than shale and it contains very salty water. Thus a route is opened for saline contamination. Some analyses of fracking water indicate that this type of problem has already been encountered in the first wells. Between the pipes and the drilled rock, and between the producing pipes and the protective sheath, the quality of the placement of the grout can leave spaces : annular fractures may also form during the intensive use of the wells. So that it is a possible origin of gas leaks coming from the wells themselves (E and K). As well as these possibilities of leaks, at the end of the well's life, probably between 2 and 5 decades after the end of operations, more generalized leaks will begin progressively, in growing proportion to the abandoned wells. The first reasons will be : 1) the disintegration of the steels and cements of the seal. 2) the pressure of the gas which builds slowly and surely on the capping. 3) the readjustment of the pressure (more precisely, the state of the constraints) in the fractured rock will slowly readjust, shearing off or deforming locally sections of the pipes. The Utica strata tend to inflate when exposed; the same property in the depths will tend to flow and close up the opened fractures a bit over time. The fractured shale will thus tend to lose some of its permeability; but this will not be sufficient to return it to its initial impermeability. On the contrary, these micro ruptures will contribute to the liberation of yet more methane over time. We are dealing here with structures which will disintegrate in extremely salty environments underground far from all possibility of inspection and maintenance, in rock transformed by the operations of hydraulic fracturing. The flow of fluids, saline water and methane will become modified. All the structures linking the surface of the transformed Utica will sooner or later attain an advanced degree of decomposition. The wells will reach a state where their function as sealing devices will no longer be operational. That means what exactly? : mega-problems at each of the wells, means of mitigation to be put in place , complex studies to be undertaken to try to find a solution, BAPE commissions for each site? (see my analysis of the Mercier case in my preceding text) There will be many of the 20,000 , maybe between 250 and 500 new cases per decade in one generation. Billions to plan for in the budget of Qu�bec. If the heads of the wells are kept accessible for perpetuity, rather than restore the surface, one would have a less complex task, because one could sound the ground and know when catastrophe threatens. Yet no one anywhere is proposing that. It is said that the site must be restored at the conclusion of the extraction. All that means is burying and forgetting the problem until it hits us in the face. Finding a solution at that point will be an impossible task, as it is impossible to obliterate a well . The hole remains there, even if one tries to plug it with something else, that other material will never have the same properties as the shale that has been drilled and fractured. This Utica Shale has contained the gas for 400,000,000 years. All our technology, present and future will never manage to do that well. Regulations cannot make fracking safe. No amount of regulation can control migration of fluids released by hydraulic fracturing. It's actually based upon very simple physics. Joe Levine NYH2O / DCS / Citizens For Water

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Comment From: Bernard Handler

3/30/18 @ 7:12 AM

I want to thank you for coming to the conclusion that there is no way of ensuring the protection of the DRB waters, if fracking for natural gas was permitted. Banning it was the only scientific and rational solution that good be reached. Thank you fo...↓

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Comment From: John Lawrence

3/30/18 @ 7:12 AM

Dear Commission, I write to oppose the Commission's proposal that effectively bans natural gas development in the Delaware River Basin region. Our nation's public policies---at all levels of government---must be based on evidence, science, and...↓

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Comment From: Dominic Galante

3/30/18 @ 7:09 AM

To Whom It May Concern: I am writing this letter as a submission to the public comment period ending March 30, 2018, on proposed amendments to the administrative manual and special regulations regarding hydraulic fracturing activities. First, I...↓ applaud the Commission's recommendation to ban high volume hydraulic fracturing in the Delaware River Basin. Thank you for proposing this rule to protect our drinking water from the clear danger that hydraulic fracturing presents. I strongly urge the adoption of this recommendation. Second, I urge you not to merely require Commission approval for the importation into the Basin, and treatment and discharge within the Basin, of wastewater from hydraulically fractured oil and gas wells. I urge you to ban outright any such importation of wastewater from hydraulic fracturing operations. The Commission has pointed to the fact that hydraulic fracturing wastewater (also known as produced water) often contains "high concentrations of total dissolved solids ... that may be harmful to human health and the environment." These include salts, metals, and radioactive materials, some of which the Commission admits "that most publicly owned treatment works ... are not designed to remove". We already know of instanced where produced water has passed through treatment facilities and still resulted in higher concentrations of chloride and bromide, resulting in cancer causing agents in the water. Produced water will impact the health of humans, livestock, agriculture, and natural environment in the region. Furthermore, as some chemicals used in the hydraulic fracturing process are considered "Confidential Business Information," the public has no way of knowing what chemicals could end up in the wastewater and, if any wastewater is allowed to pass into the Delaware River Basin, on into our drinking water. It is unconscionable to allow even the remotest possibility of unknown chemicals into our drinking water. Our health and the knowledge of what goes into our bodies is more important than the trade secrets of a private business. Finally, the Commission has also pointed out that the regulation of produced water largely remains outside current federal regulations. Therefore, the Commission has the responsibility to fill the gap where federal regulation does not exist. And this is a great opportunity to set a strong precedent for the rest of the country and send a message that the health of our citizens is one of the most important priorities of our government. We have seen regulators and regulations fail in this regard, especially in the case of the city of Flint, Michigan, but also in dozens of other areas. The people of the Delaware River Basin do not want to become another case of negligent government oversight and suffer the awful health risks that these chemicals can bring. Please make a blanket ban on importation of hydraulic fracturing wastewater into the Delaware River Basin. Sincerely, Dominic Galante

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Comment From: Michael Hawkins

3/30/18 @ 7:08 AM

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Comment From: Joe Levine

3/30/18 @ 7:05 AM

DRBC Determination on Fracking: I applaud the DRBC and the governors of 4 states who come together to support a Fracking Ban in the DRB. This river is way too valuable and irreplaceable to expose to the cumulative detrimental impacts of fracking....↓ The Commission determination that; "...high volume hydraulic fracturing poses significant, immediate and long-term risks to the development, conservation, utilization, management, and preservation of the water resources of the Delaware River Basin and to Special Protection Waters of the Basin, considered by the Commission to have exceptionally high scenic, recreational, ecological, and/or water supply values. Controlling future pollution by prohibiting such activity in the Basin is required to effectuate the Comprehensive Plan, avoid injury to the waters of the Basin as contemplated by the Comprehensive Plan and protect the public health and preserve the waters of the Basin for uses in accordance with the Comprehensive Plan." I know that this commission did not come to this determination hastily - in fact it has been dealing with this issue for 10 years. It has been adequately proven by numerous state and independent studies in Fracking areas - encompassing thousands of hours, including comprehensive studies by NYC and NYS that fracking and it's Cumulative Impacts is hazardous to your health and must to be banned. Let's not forget that he Industry plan in 2008 called for more than 20,000 wells in the DRB. This would have resulted in the environmental devastation of this region and the loss of this pristine water supply. Treatment Frack Waste Water: Last week The NY Times published an article called Billion Dollar Investment to Protect the "Champagne of Drinking Water". It notes in the article that NYC will spend some $200 million of the annual billion dollars on maintenance and upgrading of wastewater treatment plants. Stating that ensuring the adequate collection and treatment of wastewater is crucial because it will be released back into the environment and eventually reaches the streams and rivers that feed the reservoirs; or in our case feed the river and aquifers in (and out of) the DRB. Toxic fracking wastewater is hazardous to the environment and our health, and its movement, storage and disposal is notorious for leaking and spilling and cannot be adequately controlled. Injection wells leak into aquifers and it cannot be cleaned. It costs way to much to regulate, control and protect and it is much more economical to eliminate as a potential problem - before it is ever allowed. Out of Basin Water Use for Fracking: It makes no sense to allow water from the DRB to be taken out of the river and used elsewhere - especially for any fracking related uses. This depletes the resource and because it has been determined that Fracking is hazardous to the environment and health and it should not be assisted elsewhere.

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Comment From: Joe Levine

3/30/18 @ 7:03 AM

Comments on DRBC Draft Frack Regulations - Proposed New 18 CFR Part 440 ● There is significant evidence that natural gas development, and its related operations, which include all the phases of the hydraulic fracturing ("fracking") process, from t...↓he first stage of industrial land preparation; to the storage, handling, and use of chemicals and additives for extraction and stimulation; to drilling and fracking; to the withdrawal of and degradation of large volumes of water and its discharge and disposal as waste, has substantial adverse effects on public health, property interests, agriculture, and on our air, water, and land. ● The most recent statistical analysis of the body of scientific literature by the Concerned Health Professionals of New York and Physicians for Social Responsibility, 685 peer-reviewed papers examining gas drilling and/or hydraulic fracturing ("fracking") were reviewed and the overwhelming majority of studies found evidence of or potential adverse impacts on water, air, and human health. ● There is significant evidence that natural gas development, and its related operations, which include all the phases of the hydraulic fracturing ("fracking") process, from the first stage of industrial land preparation; to the storage, handling, and use of chemicals and additives for extraction and stimulation; to drilling and fracking; to the withdrawal of and degradation of large volumes of water and its discharge and disposal as waste, has substantial adverse effects on public health, property interests, agriculture, and on our air, water, and land. ● WASTES -Substantial damage is caused by the toxic wastewater produced by fracking which contains many dangerous pollutants, including naturally occurring radioactive materials, that cannot be fully removed by treatment and those damages can substantially harm the water quality of our streams and the life in them. Pollutants will inevitably spread downstream to negatively impact all of the watershed states, the habitats, fish, wildlife, and recreational values of the river and our vulnerable drinking water supplies. There is a moratorium on all gas drilling, hydraulic fracturing (fracking), water withdrawals for and wastewater treatment and discharges from fracking throughout the entire Delaware River Basin today, since 2010. ● The moratorium was put in place by the Delaware River Basin Commission (DRBC), the federal-interstate agency that manages the water resources of the Delaware River Watershed. The DRBC members – the Governors of Pennsylvania, New York, New Jersey, and Delaware, and the federal government – have the responsibility of protecting the shared waters that provide 15-17 million people in all four of the Watershed states with drinking water, including New York City and Philadelphia. ● A complete and permanent ban on natural gas drilling and fracking and all related activities (including wastewater processing and discharges from and water withdrawals for drilling and fracking operations) throughout the Delaware River Watershed is needed because the only sure way to prevent pollution from fracking and its activities is to totally ban it. It makes no sense to ban fracking but allow its toxic waste to be dumped in the Watershed and our precious fresh water to be depleted for fracking. ● Fracking uses enormous volumes of water, approximately 5 to 10 million gallons per well per frack (there can be several fracks to release the gas), and increases beyond 10 million gallons are becoming more frequent, and all of that water is lost – either through pollution or by being consumed since most of the water injected for fracking is not recovered and returned to the source, depleting the streams and/or groundwater from where it is taken. ● Air emissions and water pollution have greater adverse health impacts on those who reside work, go to school, or frequent the zone within approximately 2 miles from the gas operation. Studies show that those closest have greater exposure and are more likely to develop disease and other health problems. ● Pennsylvania Department of Environmental Protection has determined that oil and gas operations have contaminated 301 private water well cases. Over 4,400 water complaints related to oil and gas have been filed by the public with PADEP. Between 2004 and 11.2016, PADEP lists 9,443 public complaints about environmental problems in shale gas drilling areas. ● EPA's most recently released fracking study provides scientific evidence that fracking activities can impact drinking water resources and includes water impacts from shale gas in the Pennsylvania community of Dimock. ● Fracking pollutes groundwater, destroying the quality of aquifers for generations to come. The chemicals in fracking fluids will migrate to drinking water aquifers and to the surface – it is not a question of "if", but "when". Considering groundwater flow, time, and the corrosive downhole environment created by gas extraction processes, including the lack of durability of the cement sealant and steel well casings, aquifers and surface waters are not sufficiently isolated from the toxic fluids and deep geology pollutants that are distributed by drilling and fracking. Aquifers could be impacted quickly, such as when there is a faulty cement seal or casing during construction, or over time. But it is certain that the life of the cement and/or steel (usually 80 to 100 years or less) is less than the life of the aquifer - so even if there is no evidence in the near term, the eventual pollution likely occur in less than a century - ruining water sources for the generations that will follow. The potential for fracking fluids to move from the production zone of a gas well to water resources "cannot be engineered out of the process (Gassiat et al. 2013). In other words, the process of injecting fluids into and fracturing the shale causes the potential pollution problem." Contaminated fluids from the fracking process can move from the deep shale to water resources through various pathways including fractures and natural vertical flow, in thousands of years or in less than ten years, polluting groundwater. ● Changes to stream water quality occur where gas drilling and related activities are located. For instance, a publication of the Proceedings of the National Academy of Sciences found streams adjacent to gas wells are negatively impacted by runoff and sedimentation (Total Suspended Solids), harming benthic life, fish and wildlife and causing streams to be eroded and destabilized. ● The natural gas industry has received unprecedented exemptions from our nation's most important environmental and public health laws, including the Safe Drinking Water Act, Clean Air Act, and the Clean Water Act. ● After exhaustive study, the State of New York prohibited fracking based on environmental and public health analysis. The NY Department of Health concluded that the overall weight of the evidence demonstrated the likelihood that adverse health outcomes and environmental impacts from fracking could not be prevented, leading to the Governor's decision to ban high volume hydraulic fracturing in the state. The State of Maryland permanently banned fracking after 2 years of study, based on the potential for adverse public health and environmental impacts. ● The Delaware River was designated as a national Wild and Scenic River by Congress because of its outstanding features, irreplaceable resources, exceptional water quality and scenic and recreational value. These prized assets provide important economic benefit to all four states whose tributaries flow to the Delaware River. These values are gravely jeopardized by fracking and its polluting operations and must be protected for the public and future generations. ● The entire nontidal Delaware River is protected by DRBC's Special Protection Waters anti-degradation regulations that do not allow water quality to be degraded in any way. We are dependent on that protection to keep our water safe. The draft regulations: ● Ban high-volume hydraulic fracturing (HVHF) in all "hydrocarbon bearing rock formations" (Part 440.3). This includes geographically the entire Delaware River Basin but it only bans "high-volume" fracking, which means fracking in deep formations that require large amounts of water. The definition of HVHF is using more than 300,000 gallons during all stages of well drilling (Part 440.2). Practically speaking, this may be all fracking in the Watershed due to the type of geology here and unlikely economic viability of shallow gas formations but there is a loophole for shallower rock formations that could be exploited. ● Do not apply to pipelines or compressor stations, only to fracking of gas wells (Part 440) ● Allow the discharge of frack wastewater to the waterways of the Watershed if approved by the DRBC. There is no safe or thoroughly effective way to treat and discharge the highly toxic materials in frack wastewater. This opens the door to highly toxic pollutants entering the waters of the Basin, many of which have never been present. This represents a degradation of the Basin's water quality. By current regulation, the DRBC cannot allow the high existing water quality of the Basin to be degraded. It's also very difficult to remove all the pollutants from frack wastewater because the constituents in frack wastewater vary tremendously due to the various formulas of frack fluids used. So, the waste varies from company to company and the materials used in fracking fluids number into the high hundreds – at least 750 different constituents. Many are not regulated at all and many are kept secret due to the shield allowed drillers to not disclose fully the "recipes" they use for the fracking process. Also, the wastewater that is produced from the deep rock formations is contaminated with naturally occurring pollutants such as radioactive materials, heavy metals, potent salts, and hydrocarbons and that is in the mix that becomes the wastewater. The NORM (Naturally Occurring Radioactive Materials) can reach concentrations magnitudes greater than health limits. ● Allow the withdrawal and transfer of water out of the Basin to other locations where fracking is permitted. This depletes the Delaware River Watershed's water because it will never return to the source and the water is either lost to the hydrologic cycle or transformed into a polluted material, never to be restored to its original quality. It is also unjust to use the Delaware to fuel fracking out of the Watershed. ● Although not directly addressed in the draft regulations, the rules may allow the injection of wastewater within the Basin. Injection of wastewater does not "treat" waste or remove contaminants, it simply moves the potential for environmental and water resource pollution and water quality degradation from one place and time to another. The draft regulations do allow the storage of wastewater. Injection wells are causing earthquakes in Ohio and Oklahoma as well as other locations and are not leak-proof, exposing groundwater and aquifers to contamination from the toxic mix that constitutes frack wastewater. ● Also not directly addressed in the draft regulations is the storage of natural gas liquids in the Watershed. These hazardous liquids cannot be stored safely in underground caverns, which as prone to leakage and are unstable.

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Comment From: Michael Hawkins

3/30/18 @ 7:00 AM

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Comment From: John Stone

3/30/18 @ 6:58 AM

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Comment From: Joe Levine

3/30/18 @ 6:55 AM

Many people representing many organizations have been attending DRBC hearings since 2007 when fracking made it's way into the East via PA. We have submitted literally 100's of reports and documents and even more comments. Because of ongoing accumulat...↓ion of evidence from drilling zones they remain even more relevant today to inform about the deleterious impacts of hydro-fracking. The first major independent study was the Hazen and Sawyer report which determined that the risks from fracking would be catastrophic and which led to NYC's ban in their watershed (which is the headwaters of this watershed with the same geological characteristics). The Report identified a number of serious risks "including but not limited to chemical contamination of surface and ground water, risks to infrastructure, and the industrialization of the watershed...all pose an unacceptable threat to the water supply of nine million New Yorkers and are inconsistent with the principles of source water protection and pollution prevention". The report also discusses Cumulative Impacts of hundreds or thousands of wells over many years, including well pad construction, tree clearing, road building, gathering lines, pipelines, compressor stations and related infrastructure, truck traffic, waste water disposal, spills, noise, air pollution, exposure to toxic chemicals. Threats to agriculture and soil quality. Intense industrialization. The NYS Watershed Inspector General commissioned an independent study by Arcadis US (one of the largest environmental engineering firms in the world usually hired by Industry) and they came to the same conclusions. The USGS has written dozens of papers reporting on the detrimental impacts to air, water, habitat and landscape. And earthquakes. And in the great state of NY where they actually conduct environmental impact studies - The State Environmental Quality Review Act (PA and NJ do not) they received more than 200,000 comments including thousands of scientific studies and reports, providing overwhelming proof of the damage that fracking can do to the environment and human health. NYS banned fracking. After an extensive (more than four year) study it came down to Health Impacts. (See: A Public Health Review of HVHF for Shale Gas Development, Dec 2014. NYSDOH) Contrary to overwhelming evidence the industry claimed (and I think still does) that it is safe to frack because they use only sand, soap and water. This has long ago been proven false - they use extremely toxic chemicals that can migrate long distances and that do contaminate water supplies.. One of the studies submitted to NYS (and also to this Commission), The Compendium of Scientific, Medical, and Media Findings Demonstrating Risks and Harms of Fracking is a compilation of more than 900 independent studies - all coming to the inevitable conclusion that there is a proven risk to public health from fracking. Fracking is also not the economic bonanza we were lead to believe and the Industry regularly and still makes inaccurate jobs claims. Economic reports prove otherwise. (Socioeconomic Value of the DRB in Delaware, NJ, NY and PA by Gerald J. Kaufman, Univ. of Delaware. Oct 11, 2011) Your wisdom in implementing a moratorium 7 years ago is a legacy you should be most proud of. We who live in the Basin are proud that together with you we have kept this place frack-free. Now that all the reasons you implemented a moratorium have been borne out, there is every reason to now turn the moratorium into a permanent ban. Future generations will thank you for your stewardship. You should be proud and now you must be strong and not give into to the fracking industry and it's financial beneficiaries. It never was about national security. But it will be at the expense of the public health, wildlife habitat, landscape, air and the incredible special protection waters of the Delaware River Basin.

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Comment From: Marybeth Diss

3/30/18 @ 6:55 AM

As one of the 1.3 million supporters of the National Parks Conservation Association, I support and applaud the Delaware River Basin Commission's (DRBC) proposed ban on high volume hydraulic fracking within the Delaware River Basin. Fracking is terrib...↓

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Comment From: Thomas Gotwols

3/30/18 @ 6:52 AM

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Comment From: Shirley Masuo

3/30/18 @ 6:48 AM

Regarding natural gas drilling WASTE DISPOSAL in the DRB: My name is Shirley Masuo and I live in the DRB in Shohola, PA. I also work in the DRB in Narrowsburg, NY. The organization I work with is currently conducting a survey of the people INCLU...↓DING WORKERS FOR THE NATURAL GAS INDUSTRY who have been impacted by natural gas activity. http://www.damascuscitizensatsdr.org These surveys and the supporting documents to back up what these people are reporting, have been sent to, and officially recorded by the Agency for Toxic Substances & Disease Registry (ATSDR) - a part of the CDC. The ATSDR has in turn, sent this information to the PA Department of Health, which is now also making a registry of them and interviewing the survey-takers to verify what is in the surveys. This is a comment from one of the surveys from a former worker for the industry from the Dimock, PA area. "I did brine spreading myself for Chesapeake. We also used to haul synthetic or inverted mud as well. They said, "we're going to call it 'water'". We were told to dump 5,000 gallons of flowback in the Susquenanna many times, also on back roads, in farms fields, etc. We would do that 2 or 3 times a day. We would dump in into the sewer plant in Great Bend - right into the sewer system. Finally, the sewer authority found out and welded the manhole covers shut." I hope the DRBC is not so naive as to think that this kind of dumping will not happen in the DRB and in the Delaware River, the source of drinking water for millions of people. The industry is having a lot of trouble with their waste disposal. Discovery of earthquakes resulting from their waste injection wells are forcing them to stop that process and there has been a clamp down on waste in uncovered pits. What else can we expect them to do with it but dump it? There has also been a lot of coverage of accidental spills of frack fluid and frack waste all over the country. There is no way to get many of the chemicals and heavy metals out of the waste water. We cannot afford to pollute our drinking water. Please ban natural gas drilling in the DRB and natural gas waste from being disposed of in the DRB or "treated" in the DRB. Also, allowing the industry to use fresh water from the Delaware River for natural gas activity in other areas only serves to allow the industry to continue to harm the health and welfare of people in nearby areas. Please ban natural gas drilling, natural gas waste disposal, and the removal of fresh water from The Delaware River for natural gas activity.

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Comment From: Elaine Miles

3/30/18 @ 6:46 AM

For the sake of common sense I very strongly oppose any forward motions on fracking.

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Comment From: Hadassah Mitchell

3/30/18 @ 6:43 AM

Hi my name is Hadassah I am 11 years old and I live in New York City. I think you should ban everything regarding fracking because of my concern as an 11 year old you should keep all water healthy and clean. We all need water, and we need clean wat...↓

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Comment From: Gail Brunner

3/30/18 @ 6:40 AM

To the Honorable Members of the DRBC, This is my last opportunity as a public human being to comment to the DRBC to fight for our lives about fracking as today is March 30 the last day the public has an opportunity to comment. I am asking that you ...↓

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Comment From: Bonnie Loewenstein

3/30/18 @ 6:39 AM

The DRBC's proposed fracking regulations are a half-measure that won't protect the Delaware River Basin, or the people who rely on it. The regulations leave the door open to both fracking waste and water withdrawals for fracking, endangering a dr...↓

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Comment From: Richard Ashworth

3/30/18 @ 6:32 AM

I am opposed to the process of Hydraulic Fracturing (Fracking) for extracting natural gas in the Delaware River Basin. I support a Ban on this practice. I am opposed to Fracking for the following reasons: The amount of fresh water required for e...↓

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Comment From: Kathleen Taylor

3/30/18 @ 6:31 AM

Ban fracking! Please, ban water withdrawals used for fracking! Keep the water clean and safe!

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Comment From: Gerald Brown

3/30/18 @ 6:30 AM

Dear Commission, I write as a member of America's energy industry to say that I strongly oppose the DRBC's proposed rule to severely limit and thereby effectively ban hydraulic fracturing within your jurisdiction. Our industry serves the natio...↓

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Comment From: Delaware Riverkeeper Network (Tracy Carluccio)

3/30/18 @ 6:26 AM

Attached are two PDFs: 1) Delaware Riverkeeper Network Petition Text 2) List of Signatories

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Comment From: Terry Nielsen

3/30/18 @ 6:24 AM

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Comment From: Grassroots Environmental Educa... (Ellen Weininger)

3/30/18 @ 6:24 AM

52 Main Street

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Comment From: Catherine Woods

3/30/18 @ 6:15 AM

I live near the deleware and I cant believe this is happening to out waterways bad enough what is already happening in there.

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Comment From: Theodore Gordon Flyfishers, In... (Stephen Lieb)

3/30/18 @ 6:12 AM

Please see the attached letter submitted by Theodore Gordon Flyfishers, Inc.

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Comment From: Delaware Riverkeeper Network (Tracy Carluccio)

3/30/18 @ 6:11 AM

Proposed Draft Regulations Addressing Hydraulic Fracturing and Additional Clarifying Amendments Please find attached 3 PDFs - 1. Delaware Riverkeeper Network Comment Re. Proposed New 18 CFR Part 440 - Hydraulic Fracturing in Shale and Other Format...↓

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Comment From: Christian Bardo

3/30/18 @ 6:08 AM

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Comment From: Andrew Benson

3/30/18 @ 6:08 AM

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Comment From: Ron Hine

3/30/18 @ 6:06 AM

Fracking pollutes water, even when the operations are regulated. If allowed in the Delaware River Watershed, over 15 million people's water would be at risk.[1] Pennsylvania Department of Environmental Protection (PADEP) has determined that there are...↓

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Comment From: Keith Pacheco

3/30/18 @ 6:01 AM

Fracking is a very dangerous activity that threatens the quality of life where ever it occurs. It is bad enough when it occurs out in the wilderness and only affects a small number of people. The damage to be done in the Delaware River Basin where...↓

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Comment From: Sam Porfido

3/30/18 @ 5:56 AM

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Comment From: Lauren Bailey

3/30/18 @ 5:55 AM

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Comment From: JOSEPH PRISELLA

3/30/18 @ 5:51 AM

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Comment From: Tracy Carluccio

3/30/18 @ 5:51 AM

Please find attached 3 PDFs - 1. Delaware Riverkeeper Network Comment Re. Proposed New 18 CFR Part 440 - Hydraulic Fracturing in Shale and Other Formations; Proposed revisions and additions to section 18 CFR 401.35 relating to project review class...↓

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Comment From: Matthew Lipschik

3/30/18 @ 5:37 AM

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Comment From: New Jersey Sierra Club (Jeff Tittel)

3/30/18 @ 5:33 AM

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Comment From: William Chase

3/30/18 @ 5:30 AM

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Comment From: William Kitz

3/30/18 @ 5:15 AM

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Comment From: Sarah Vogwill

3/30/18 @ 5:12 AM

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Comment From: Margery Schab

3/30/18 @ 5:11 AM

There should be no water withdrawal from the Delaware River Basin for fracking purposes. That water is for the use of citizens and the preciousness of good water should appreciated. 17 million people rely on the water from the Basin. The entire pr...↓

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Comment From: Raymond McAndrew

3/30/18 @ 5:08 AM

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Comment From: Responsible Drilling Alliance (Barbara Jarmoska)

3/30/18 @ 5:07 AM

This is an edited version of a comment submitted circa 11:45 am on March 30th. I apologize that I failed to send the final version the first time. You may delete the earlier file from your records and replace it with this. Thank you. Barb...↓

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Comment From: Terence Manno

3/30/18 @ 5:04 AM

The regulations proposed by the DRBC concerning our countries energy independence is completely one sided. I disagree with the proposed regulations and believe the DRBC needs to look at the facts of the tens of thousands of wells drilled in the State...↓

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Comment From: Daniel Carr

3/30/18 @ 4:58 AM

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Comment From: JUDITH MARTIN

3/30/18 @ 4:50 AM

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Comment From: Jack Ray

3/30/18 @ 4:48 AM

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Comment From: American Petroleum Institute (Stephanie Meadows)

3/30/18 @ 4:48 AM

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Comment From: JUDITH MARTIN

3/30/18 @ 4:48 AM

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Comment From: Responsible Drilling Alliance (Barbara Jarmoska)

3/30/18 @ 4:47 AM

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Comment From: JUDITH MARTIN

3/30/18 @ 4:44 AM

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Comment From: Len Fennessy

3/30/18 @ 4:41 AM

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Comment From: Christina Surowiec

3/30/18 @ 4:40 AM

Please accept attached .pdf file as my written comment.

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Comment From: Debi Slatkin

3/30/18 @ 4:34 AM

You need only look as far as the exhaustive studies by DRBC member states New York and Maryland—states that have banned fracking based on evidence—to find the likelihood that fracking and its associated activities cause adverse health outcomes and en...↓

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Comment From: Beth Ann Pollack

3/30/18 @ 4:33 AM

From: Beth Ann Pollack 22 Firtree Rd. Levittown, PA 19056 [email protected] To: The People of the Delaware River Basin Commission Date: March 29, 2018 Subject: Fracking Would Affect Your Families Too! The water of the Delaware Rive...↓

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Comment From: Shaleen Gilman

3/30/18 @ 4:33 AM

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Comment From: Darren Strain

3/30/18 @ 4:32 AM

As a conscientious citizen, taxpayer, and one of the 1.3 million supporters of the National Parks Conservation Association, I support and applaud the Delaware River Basin Commission's (DRBC) proposed ban on high volume hydraulic fracking within the D...↓

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Comment From: Lawrence Fitzkee

3/30/18 @ 4:31 AM

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Comment From: Walter Dannhauser

3/30/18 @ 4:26 AM

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Comment From: Bill Weaver

3/30/18 @ 4:24 AM

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Comment From: Jeffrey Gallo

3/30/18 @ 4:19 AM

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Comment From: terry swan

3/30/18 @ 4:13 AM

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Comment From: David Miller

3/30/18 @ 4:11 AM

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Comment From: Jerry Davis

3/30/18 @ 4:09 AM

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Comment From: PennEnvironment Research & Pol... (Stephanie Wein)

3/30/18 @ 4:09 AM

Delaware River Basin Commission voting members, The Delaware River provides drinking water for 15 million people. We can't let fracking poison it. Please take every step possible to keep dangerous fracking waste water away from the Delaware River....↓

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Comment From: georgette pascotto

3/30/18 @ 4:07 AM

• Do not allow fracking waste into the Del. River Basin or into the areas soil • Do not allow commercial taking of water from the basin or elsewhere.

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Comment From: Donald Holmes

3/30/18 @ 4:05 AM

I object to all fracking activities in our region. Our precious clean water resources that serve millions, and billions in property values MUST NOT be put at risk by frackers. I can't believe our legislators have allowed it to get this far. Ban it...↓

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Comment From: Al Cerreto

3/30/18 @ 4:01 AM

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Comment From: Doylestown Township (Stephanie Mason )

3/30/18 @ 3:57 AM

Our Board of Supervisors at the request of our Environmental Advisory Board adopted resolution #2013 on March 20, 2018 please see our uploaded resolution.

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Comment From: William Vaughan

3/30/18 @ 3:55 AM

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Comment From: john vegetabile

3/30/18 @ 3:54 AM

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Comment From: Tom Metzger

3/30/18 @ 3:48 AM

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Comment From: RUSSELL SWANICKE

3/30/18 @ 3:46 AM

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Comment From: Kimberly Hauer

3/30/18 @ 3:46 AM

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Comment From: Ruth Burroughs

3/30/18 @ 3:43 AM

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Comment From: jack scott

3/30/18 @ 3:43 AM

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Comment From: Arlis Stone

3/30/18 @ 3:40 AM

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Comment From: Linda Reik

3/30/18 @ 3:39 AM

The only course of action for which it is possible to preserve the waters, lands and air of our National Scenic Recreational Area in healthy condition for the benefit of Public users and all living things is that the DRBC must ban fracking in the riv...↓er basin and ban all water exchanges such as water withdrawal for frack operations and/or processed wastewater deposition into the Delaware River. To inform Commissioners of the DRBC, I'm submitting this data from the PADEP: Between 2004 and November 2016, the PADEP lists 9,443 public complaints about environmental problems in shale gas drilling areas ( https://stateimpact.npr.org/pennsylvania/2017/01/31/data-trove-offers-new-details-on-complaints-to-dep-during-shale-boom/ and https://docs.google.com/spreadsheets/d/1_tg1zTCA-). It is imperative that DRBC not take a risk of accumulating such a volume of complaints about fracking activities and then have hindsight regrets. In March 2018, the Concerned Health Professionals of New York and the Nobel Peace Prize-winning group, Physicians for Social Responsibility stated "There is no evidence that fracking can operate without threatening public health directly or without imperiling climate stability upon which public health depends" (Concerned Health Professionals of New York & Physicians for Social Responsibility. (2018, March). Compendium of scientific, medical, and media findings demonstrating risks and harms of fracking (unconventional gas and oil extraction) (5th ed.). http://concernedhealthny.org/compendium/). In today's fracking technology, the volume of liquids used to frack one well has increased 2-fold to 10 million gallons of water plus additives compared to initial industry methods, and tons of sand are being added to fracking drilling agent at the rate of one ton per foot of fracking distance. Dr. Anthony Ingraffea wrote these metrics in a March 2018 personal communication to people including me. The old estimates of 4-5 million gallons, used by DRBC, are no longer valid. Technology used today can lengthen horizontal well bores up to 4 miles, so the volumes of liquids being exchanged from and to a gas operation would be up to 2-4 times greater than it was during earlier fracking operations (http://www.post-gazette.com/powersource/companies/2018/01/15/These-days-oil-and-gas-companies-are-super-sizing-their-well-pads/stories/201801140023). The sand in frack fluid is silica sand and poses health risks including cancer to its miners and workers (Wisconsin Center for Investigative Journalism; https://www.wisconsinwatch.org/series/frac-sand/). If fracking drilling agent or waste is transported by trucks within Delaware River basin communities, residents could be exposed to air emissions and water pollution. People who live, work or go to school within approximately 2 miles of a gas operation have greater adverse health impacts. People who encounter trucks transporting drilling liquids or waste liquids have a higher risk of being harmed by truck accident and truck cargo (http://www.delawareriverkeeper.org/sites/default/files/resources/Reports/CNA Impacts in DRB.8.15.pdf ; http://www.delawareriverkeeper.org/sites/default/files/MarcellusPA_FullReport.pdf). The fracking industry is having trouble finding places to dump its frack wastewater. So much so, that industry is targeting the valuable National Scenic and Recreational Delaware River. The DRBC should make no allowance for industry to deposit frack waste in this river basin. Please enact a complete ban now.

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Comment From: Susan DeCoste

3/30/18 @ 3:38 AM

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Comment From: K .V.Adamski

3/30/18 @ 3:38 AM

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Comment From: Michael Watson

3/30/18 @ 3:38 AM

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Comment From: Luana Lewis

3/30/18 @ 3:36 AM

It would be madness to allow fracking, disposal of fracking waste, or use of water for fracking, anywhere near the Delaware watershed or any other watershed with an impact on New York City drinking water or other drinking water having an impact on hu...↓

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Comment From: geraldine coppinger

3/30/18 @ 3:36 AM

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Comment From: geraldine coppinger

3/30/18 @ 3:34 AM

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Comment From: Tricia van Oers

3/30/18 @ 3:34 AM

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Comment From: Sydney L. Waller

3/30/18 @ 3:33 AM

I am totally opposed to any more dangers to the precious Delaware River Basin. Over 15,000,000 people rely on the waters of the Delaware River Basin for drinking, agricultural and industrial use. In 1961, President John F. Kennedy and the governors o...↓

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Comment From: geraldine coppinger

3/30/18 @ 3:32 AM

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Comment From: Michael Klein

3/30/18 @ 3:32 AM

Fracking wastewater is dangerous. Dumping fracking wastewater into our river is a terrible, dangerous idea. Fracking wastewater, especially from the Marcellus Shale, contains carcinogens and is radioactive! Keep it away from the Delaware River Basin...↓

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Comment From: geraldine coppinger

3/30/18 @ 3:30 AM

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Comment From: John Bird

3/30/18 @ 3:30 AM

My comments: Fracking has caused many people in West Virginia many problems. Several health studies have shown health problems occur the closer to a well one lives. One study shows that babies born near fracking wells have a higher risk of birth ...↓

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Comment From: geraldine coppinger

3/30/18 @ 3:29 AM

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Comment From: Ann Brochhagen

3/30/18 @ 3:29 AM

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Comment From: Carin Barbanel

3/30/18 @ 3:28 AM

Hydraulic fracturing is shown to release.more harmful gasses into the air and underground aquifirs than was first thought. The permanent damage and net negatives to surrounding waterways and land make it a loss when external costs start to be dactire...↓

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Comment From: geraldine coppinger

3/30/18 @ 3:27 AM

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Comment From: geraldine coppinger

3/30/18 @ 3:25 AM

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